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Corporate Investigations & Integrity

Companies in today's regulatory environment face intense scrutiny and are increasingly being called upon to address government inquiries with high-stakes internal investigations. In these cases, it is critical to proceed with quick action and timely and careful fact-finding, with the ultimate goal of avoiding protracted investigations and achieving successful outcomes for companies and their officers and directors.

Our Corporate Investigations & Integrity Practice Group provides effective representation at all stages of legal compliance and review, from designing proactive compliance programs to addressing the challenges of a government inquiry. We also regularly conduct internal investigations on issues including employee misconduct, vendor fraud, export sanction compliance, import classification, company expenditures, and related internal controls. Our broad spectrum of clients includes individuals, corporations, boards of directors, audit committees, and government agencies.

Recognizing that a proactive approach is the most effective strategy, we work with our clients to create successful compliance programs that demonstrate and protect their integrity, and to develop standard practices that align with industry regulations. These programs reduce both the likelihood of an inquiry and the risk of an extensive investigation. When an inquiry proves inevitable, we conduct comprehensive and effective internal investigations and ensure that our clients respond appropriately to bring the situation to a swift and favorable resolution.

Discretion is paramount for our clients. They benefit from our extensive public relations experience that enables us to craft effective, tactical responses when media attention is unavoidable, as well as from the support of our White Collar Criminal Defense Practice Group. Our group also offers an important perspective: It is led by a former New Jersey state comptroller and includes several members who have held senior roles in federal and state enforcement agencies, including nine former federal prosecutors. Their experience on both sides of government inquiries gives us an in-depth understanding of the ways that government agents approach investigations, the key concerns of prosecutors and regulators, the best ways to avoid potential pitfalls, and how to effectively interact with agents during a review.

EXPERIENCE

Represented the New Jersey Division of Equal Employment Opportunity in conducting an investigation into allegations of workplace discrimination at the New Jersey National Guard.

Represented a New Jersey university in conducting an internal investigation into alleged misconduct by a senior official at the university.

Represented a social media company in conducting an internal investigation concerning possible campaign financing violations.

Represented a state agency in conducting an investigation concerning a state contract and in resolving the state's dispute with the vendor.

Represented the board of directors of a global communications company in conducting an internal investigation concerning the conduct of a senior official at the company.

Represented a Fortune 500 company in an extensive internal investigation involving allegations of wrongdoing in connection with one of the company's offices in Asia.

Represented a Fortune 500 company in an internal investigation related to several allegations that were made to the board of directors concerning the company's chief compliance officer.

Hired by the Sussex County Board of Chosen Freeholders to conduct an investigation into a solar energy initiative that had resulted in the county experiencing millions of dollars in financial losses.

Hired to conduct an investigation into the facts and circumstances surrounding a government agency's demolition of a historic house in connection with an extensive, federally funded transportation project.

Represented a Fortune 500 retailer in parallel investigations brought by the Department of Justice, the Securities and Exchange Commission, and the Internal Revenue Service regarding alleged stock options backdating, as well as related civil suits brought by shareholders. No charges were brought against the company or any of its directors or officers, and all civil claims were dismissed at the pleadings stage.

Represented the chief financial officer and chief compliance officer of a New York-based hedge fund in parallel investigations conducted by the Securities and Exchange Commission and the Commodity Futures Trading Commission involving allegations of market manipulation. No charges were brought against the executive.

Represented a securities industry professional in parallel investigations brought by the Securities and Exchange Commission, the Financial Industry Regulatory Authority, the New York Attorney General's office, and multiple state securities regulators, involving allegations of mutual fund market timing. No charges were brought against the client.

Represented numerous entities accused of FCA and FCPA violations. For example, secured a deferred prosecution agreement for a global company that provides engineering and environmental consulting services to various federal, state, regional, and local governmental and quasi-governmental agencies. The case was initially brought as an FCA Qui Tam matter, which led to an investigation of alleged FCPA violations. The lead enforcement agencies were the U.S. Department of Justice and the U.S. Attorney's Office for the District of New Jersey.

Represented numerous individuals in the banking and securities industries who were the targets of investigations conducted by the U.S. Department of Justice and the Securities Exchange Commission. Currently representing a client in connection with an SEC investigation concerning the potential mismanagement and/or misappropriation of funds of a multibillion-dollar international hedge fund.

Representing a county government in its internal investigation of participants in a renewable energy contract gone awry.

Conducted an independent investigation into allegations of workplace misconduct including sexual harassment, domestic violence, and inappropriate behavior within the Dallas Mavericks’ business operations. The seven-month investigation culminated in the release of The Report of the Independent Investigation of Dallas Basketball Limited, detailing harassment and workplace misconduct over 20 years, lack of compliance and internal controls within the organization, errors in judgment among Mavericks’ leadership, and recommendations for changes to the Mavericks’ organization.

PRESS MENTIONS

Peter D. Greeneis quoted in Barron’sdiscussing a recent lawsuit filed against The Weather Channel app by the City of Los Angeles for dishonestly gathering and selling users’ location information to hedge funds and money managers that use such data to gain insights regarding consumer behavior. Greene notes that more suits against alternative data collection could eventually be filed and advises his clients to remain vigilant with regard to data provenance. (subscription required to access article)

Sports Illustrated, The Washington Post, Forbes, the Associated Press, USA Today, CNN, ESPN, the NBA, Mavs Moneyball, ABC, CBS, MSN, SportsDay (The Dallas Morning News), the Dallas Observer, the Star-Telegram, Corporate Counsel, Law360, and numerous other outlets note Anne Milgram as co-lead attorney (alongside Evan Krutoy of Krutoy Law, P.C.) in an independent investigation on behalf of the Dallas Mavericks to look into allegations of serious workplace misconduct within the team’s business operations. A seven-month process involving 215 interviews and review of more than 1.6 million documents resulted in the September 19 release of The Report of the Independent Investigation of Dallas Basketball Limited, as well as a press conference in which Anne detailed the investigation’s methodology and the report’s findings and recommendations. Sports Illustrated describes the investigation’s approach as “thorough, objective and as complete as reasonably possible.” The article lauds that fact that the Mavericks hired two impartial, “high-caliber attorneys” and gave them “complete and unfettered access,” and it notes the NBA’s implicit endorsement of the investigation given the league’s decision not to launch its own. The NBA says that the “extensive investigation … resulted in a detailed understanding of the scope and substance of the issues.” Corporate Counsel states that the report “could hold important lessons for GCs” and that in-house counsel would do well “to study the report’s recommendations … to see what might apply at their own companies.” The Washington Post reports that NBA Commissioner Adam Silver has asked all 30 NBA teams to adopt the report’s recommendations. (subscription required to access certain content)

Matthew Boxer is highlighted on NJ.com for being hired by the state of New Jersey to investigate claims of racial discrimination made at the New Jersey National Guard. Matthew's extensive investigation experience, "unquestioned credentials," and "reputation for being objective and fair" are also discussed.